What Not to Say to an Insurance Adjuster
The insurance adjuster sounds friendly.
They ask how you're doing.
They want to know what happened.
They may tell you they just need a few questions answered so they can “move the claim along.”
That does not mean the adjuster is your advocate.
The insurance-company adjuster works for the insurance company—not for you.
Over the years, the same frustrations come up repeatedly in claim experiences shared by friends, family and consumers: estimates that seem too low, damage that gets left off the first report, early settlement offers, endless requests for documentation and seemingly harmless statements later being used to question part of a claim.
That doesn't mean every adjuster is trying to trick you.
But it does mean you should understand the relationship.
The adjuster's job is to investigate the loss, determine what the insurer believes the policy covers and calculate what the company believes it owes.
Your job is to protect your own claim by being truthful, accurate, documented and careful not to turn guesses into facts.
The most dangerous thing you can say to an adjuster may not be a lie.
It may be something you casually guessed.
Table of Contents
- Quick Answer: What Should You Not Say?
- The Insurance Adjuster Works for the Insurance Company
- Friendly Does Not Mean They Represent You
- The Biggest Claim Mistake: Guessing
- Don't Guess Speed, Distance or Time
- Don't Guess How Long Home Damage Has Existed
- Be Careful With Casual Admissions of Fault
- Be Careful Saying “I'm Fine” After an Accident
- Recorded Statements: When to Be Careful
- Your Own Insurance Company Is Different
- The Other Driver's Insurance Company
- The Early Settlement Problem
- Should You Take the First Settlement Offer?
- Never Sign a Release You Don't Understand
- The First Estimate Is Not Always the Final Damage
- Do Insurance Adjusters Try to Lowball Claims?
- How Can Adjuster Questions Hurt a Claim?
- What an Adjuster May Not Volunteer
- How to “Outsmart” an Insurance Adjuster
- Out-Document the Claim
- What Not to Say on a Home Insurance Claim
- What Not to Say After a Car Accident
- Insurance Adjuster vs Public Adjuster
- Can You Hire a Public Adjuster for an Auto Claim?
- Can You Trust Your Insurance Adjuster?
- What Are the Worst Insurance Companies to Deal With?
- How Do You Get an Adjuster to Call You Back?
- When to Escalate the Claim
- When to File an Insurance Department Complaint
- When an Attorney May Make Sense
- Better Things to Say Instead
- Bottom Line
- Related Insurance Claim Guides
- Helpful Resources
- Frequently Asked Questions FAQ’s
Quick Answer: What Should You Not Say?
Do not:
- Guess about facts you do not know
- Estimate speed or distance unless you actually know
- Guess how long a leak existed
- Volunteer that damage was “probably old”
- Casually admit legal fault
- Say you're uninjured when you genuinely don't know yet
- Exaggerate injuries or damage
- Hide prior damage
- Sign a settlement release you do not understand
- Assume the first estimate includes everything
And never lie.
The goal is not to manipulate the adjuster.
The goal is to separate what you know from what you merely think might have happened.
The Insurance Adjuster Works for the Insurance Company
This is the first thing every claimant should understand.
A company adjuster is employed by the insurer.
An independent adjuster may be an outside contractor, but when hired by the insurance company, that adjuster is still handling the claim on the insurer's behalf.
The adjuster may:
- Inspect damage
- Interview you
- Interview witnesses
- Review photographs
- Read police reports
- Review medical documentation
- Estimate repairs
- Determine coverage issues
- Recommend a settlement amount
The Adjuster Is Not Your Personal Claims Consultant
The adjuster's responsibility is to handle the insurance company's claim investigation. Do not assume they are responsible for finding every possible argument that would increase your payment.
That is why you need to understand your policy and document your own loss.
Friendly Does Not Mean They Represent You
A good adjuster should be professional.
Many are perfectly pleasant people.
That is not the problem.
The problem occurs when a claimant mistakes a friendly conversation for a confidential conversation with someone representing the claimant's interests.
It isn't.
Statements you make can become part of the claim file.
Assume Important Conversations May Become Claim Evidence
You don't need to be hostile. You do need to be accurate.
The Biggest Claim Mistake: Guessing
This may be more damaging than almost anything else.
The adjuster asks:
“How fast were you driving?”
You don't know.
But silence feels awkward, so you say:
“Maybe 45?”
Later, another piece of evidence suggests 35.
Now the claim contains two numbers.
The adjuster asks:
“How long do you think that pipe had been leaking?”
You say:
“I don't know. Maybe a few months?”
You have just potentially introduced the words “few months” into a claim involving an insurer investigating whether damage resulted from long-term leakage.
“I Don't Know” Is a Complete Answer When You Truly Don't Know
You can say:
“I don't know. I first noticed the damage on October 25. I can tell you what I observed, but I don't know when the hidden leak actually began.”
That is truthful.
It is also much better than inventing a timeline.
Don't Guess Speed, Distance or Time
Auto claims generate countless questions involving estimates:
- How fast were you going?
- How fast was the other car going?
- How many feet away were they?
- How many seconds did you have?
- How far into the intersection were you?
- How long was the light yellow?
If you actually know, answer accurately.
If you do not know, do not manufacture precision.
False Precision Can Become an Inconsistency
People are notoriously poor at estimating speed, distance and seconds during a sudden accident. A casual guess can later be compared against video, vehicle data, photographs or witness statements.
Don't Guess How Long Home Damage Has Existed
This is especially dangerous in homeowners claims involving:
- Leaks
- Mold
- Roof damage
- Rot
- Water stains
- Cracks
An adjuster might reasonably ask:
“How long has this been leaking?”
If you discovered the stain yesterday, that may be all you actually know.
Do not turn:
“I discovered it yesterday.”
into:
“It's probably been leaking six months.”
Those are completely different statements.
Give the Discovery Date, Not an Invented Damage Date
If a plumber later determines the likely cause or duration, provide the professional findings rather than guessing during the first phone call.
Be Careful With Casual Admissions of Fault
After a crash, people often say things automatically:
“I'm sorry.”
“I didn't see him.”
“It was probably my fault.”
Some are expressions of concern rather than legal conclusions.
But an insurance investigation can involve:
- Traffic laws
- Lane positions
- Witnesses
- Dashcam footage
- Police reports
- Comparative negligence
You may not yet know all of those facts.
Describe What Happened
Tell the adjuster what you saw and what you did. Let the evidence and applicable law determine fault.
Do not lie to avoid responsibility.
But you do not need to make a legal determination at the roadside.
Be Careful Saying “I'm Fine” After an Accident
This phrase gets repeated constantly after crashes.
Someone asks:
“Are you hurt?”
You answer:
“I'm fine.”
Maybe you are.
But immediately after an accident, you may simply mean:
“I am conscious and don't need an ambulance right this second.”
Some symptoms can develop or become more noticeable later.
A more accurate response when you genuinely do not know is:
“I don't know yet. I'm shaken up and will monitor how I feel.”
Don't Fake an Injury Either
There is a big difference between avoiding a premature medical conclusion and exaggerating or inventing symptoms. Insurance fraud can create serious legal problems.
Recorded Statements: When to Be Careful
Recorded statements deserve special attention because there are two very different situations.
The Other Driver's Insurance Company
You generally do not have the same contractual relationship with the other driver's insurer that you have with your own company.
If that adjuster asks for a recorded statement, you can ask:
- Why is it needed?
- Is it required?
- What subjects will be covered?
- Can I provide information another way?
You might say:
“I'm not comfortable giving a recorded statement at this time.”
Your Own Insurance Company
This is different.
Your policy may require you to cooperate with your insurer's investigation.
The company may be entitled under the policy to request:
- A written statement
- A recorded statement
- Documentation
- An examination under oath in certain claims
Don't Use Internet Advice to Breach Your Own Policy
Blanket advice saying “never give any insurance company a statement” can be dangerous when it is your own insurer requesting information under your contractual duties.
If the claim is serious and you are unsure about your obligations, consider obtaining appropriate professional advice before refusing a policy request.
Your Own Insurance Company Is Different
Your own insurer owes obligations under your insurance contract and applicable state claims laws.
You also have obligations.
Those can include:
- Promptly reporting the loss
- Cooperating with the investigation
- Providing requested documentation
- Protecting property from additional damage
- Allowing inspections
Your strategy should therefore not be:
“Say nothing.”
It should be:
“Answer accurately, document everything and don't speculate.”
The Other Driver's Insurance Company
A third-party adjuster has a different relationship with you.
You are making a claim against that insurer's policyholder.
The adjuster is investigating:
- Whether their driver was legally responsible
- Whether you contributed to the accident
- Whether your injuries were caused by the crash
- Whether your medical treatment is reasonable
- How much your vehicle damage is worth
- How much the company should offer to settle
Remember Who the Customer Is
The other driver's insurer did not sell you the liability policy and is not acting as your representative.
The Early Settlement Problem
An early settlement can be attractive.
Your car is damaged.
You missed work.
Bills are arriving.
Then the adjuster offers money.
Fast money feels like a solution.
The problem is that you may not yet know:
- Whether additional vehicle damage exists
- Whether your injury needs more treatment
- Whether you will miss additional work
- Whether surgery will be recommended
- Whether symptoms will resolve
A settlement may require signing a release ending further claims arising from the accident.
Should You Take the First Settlement Offer?
Not automatically.
The first offer might be perfectly reasonable.
It might also be incomplete.
Before accepting, compare it against:
- Repair estimates
- Vehicle valuation
- Medical bills
- Future treatment
- Lost wages
- Rental expenses
- Other covered losses
Ask How the Number Was Calculated
You do not have to reject an offer simply because it is the first offer. But you should understand what the offer includes before agreeing that the claim is finished.
See Insurance Adjuster Lowballed You? Don't Accept Until You Check These Numbers.
Never Sign a Release You Don't Understand
This can be especially important in injury claims.
A settlement check may come with a release stating that you give up future claims relating to the accident.
Before signing, understand:
- Who is being released
- Which claims are being released
- Whether property damage is included
- Whether bodily injury is included
- Whether future medical expenses are included
- Whether the settlement is final
A Settlement Can End the Claim
Do not assume you can accept the money now and simply reopen the claim months later if additional problems appear.
The First Estimate Is Not Always the Final Damage
This matters in both auto and home claims.
Auto Claim
The adjuster sees:
- Damaged bumper
- Broken light
- Dented panel
The body shop removes the bumper and finds:
- Broken brackets
- Sensor damage
- Structural damage
- Calibration requirements
The shop may submit a supplement.
Home Claim
The adjuster sees a wet ceiling.
The contractor later discovers:
- Wet insulation
- Hidden framing damage
- Electrical damage
- Mold
- Additional damaged drywall
Initial Estimate Does Not Always Mean Final Claim
If legitimate covered damage is discovered later, document it and ask about the insurer's supplemental claim process.
Do Insurance Adjusters Try to Lowball Claims?
Consumers use the word “lowball” whenever the insurer's estimate is substantially below what they believe the loss is worth.
That can happen for different reasons.
The adjuster may:
- Miss damage
- Use different labor rates
- Use different replacement materials
- Apply depreciation
- Disagree about cause
- Disagree about repair methodology
- Use a different vehicle valuation
Sometimes the insurer's number may be justified.
Sometimes it may not be.
“That's Too Low” Is Not the Strongest Argument
A contractor estimate, body-shop supplement, comparable vehicle listings, photographs and policy language are much more persuasive than simply telling the adjuster the offer feels insulting.
How Can Adjuster Questions Hurt a Claim?
I would not assume every question is a deliberate trap.
Adjusters genuinely need information to investigate claims.
But questions can still create problems when the claimant answers beyond what they actually know.
For example:
“Was the Floor Already Damaged?”
Bad response:
“Maybe. It's pretty old.”
Better:
“There was no visible water damage that I was aware of before this loss.”
“How Long Was the Roof Leaking?”
Bad response:
“Probably years. The roof is old.”
Better:
“I first discovered water inside the house on October 28. I don't know when the leak began.”
“How Fast Were You Going?”
Bad response:
“Probably 50.”
Better:
“I don't know my exact speed.”
The Pattern Is Simple
Don't replace missing facts with guesses.
What an Adjuster May Not Volunteer
Do not expect every adjuster to proactively teach you every strategy that could increase your claim.
You may need to ask about:
- Supplemental estimates
- Replacement-cost reimbursement
- Recoverable depreciation
- Appraisal provisions
- Rental reimbursement
- Loss-of-use coverage
- Additional living expenses
- Diminished value
- Contents coverage
- Deadlines
Not every one of these applies to every claim.
But if you do not understand what your policy provides, ask.
How to “Outsmart” an Insurance Adjuster
Don't.
Trying to trick someone who handles claims for a living is not a serious strategy.
There is a much better approach:
Out-Document the Claim
Photos, videos, receipts, estimates, emails, timelines and policy language are much more useful than clever answers.
The strongest claimant is often the boring claimant who can produce:
- Date of loss
- Photographs
- Police report
- Contractor estimate
- Repair estimate
- Receipts
- Medical documentation
- Written timeline
- Copies of every insurer communication
Out-Document the Claim
Photograph Everything
Take wide photos and close-ups before cleanup or repairs whenever safely possible.
Keep a Claim Timeline
Write down every call, email, inspection and request.
Use Email
After an important phone conversation, consider confirming key points in writing.
Save Estimates
Keep contractor, body-shop and replacement estimates.
Save Receipts
Temporary repairs, towing, rentals and mitigation expenses can matter.
Keep the Policy
Ask which policy provision supports a coverage decision you don't understand.
What Not to Say on a Home Insurance Claim
Be especially careful with statements such as:
“It's Been Leaking for Months.”
Don't say this unless you actually know it is true.
“The Roof Was Already Bad.”
Describe known prior conditions accurately, but don't casually diagnose the entire roof.
“I Haven't Maintained Anything in Years.”
Answer maintenance questions honestly, but broad exaggerations can create confusion.
“It's Probably Mold Everywhere.”
Describe what you see. Let qualified professionals determine the extent.
“Whatever You Think Is Fine.”
You are allowed to review the estimate and ask questions.
Don't Hide Pre-Existing Damage
Being careful does not mean concealing facts. Misrepresentation can jeopardize the entire claim.
What Not to Say After a Car Accident
Avoid turning uncertainty into admissions.
Be cautious with statements like:
- “It was completely my fault.”
- “I was probably speeding.”
- “I never saw the other car.”
- “I'm totally fine.”
- “The car wasn't worth much anyway.”
- “Whatever you offer is fine.”
Give factual information instead:
- Direction of travel
- Lane
- Traffic signal
- Observed damage
- Known witnesses
- Police-report information
See What to Do After a Car Accident.
Insurance Adjuster vs Public Adjuster
These titles sound similar but represent completely different relationships.
| Insurance Company Adjuster | Public Adjuster |
|---|---|
| Works for or is hired by insurer | Hired by policyholder |
| Investigates claim for insurer | Advocates for insured in covered property claim |
| Paid by insurer | Usually paid by policyholder |
| No separate claimant contract fee | Usually requires contract |
| Handles many types of claims | Most commonly associated with property/home claims |
A Public Adjuster Actually Represents the Policyholder
That is the key difference. You hire and compensate the public adjuster to assist with documenting and negotiating your claim.
See Pros and Cons of Hiring a Public Adjuster for Home Insurance Claims.
Can You Hire a Public Adjuster for an Auto Claim?
There is no broad nationwide equivalent to the homeowner public-adjuster model for routine auto claims.
Public adjusters are primarily associated with first-party property claims such as:
- Hurricane damage
- Fire damage
- Water damage
- Roof claims
- Large homeowners losses
For an auto valuation or repair dispute, other options may include:
- Your body shop
- An independent vehicle appraiser
- The appraisal process if provided by the policy
- A diminished-value appraiser
- Your state insurance department
- An attorney when a legal dispute justifies one
Auto Claims Usually Use Different Dispute Tools
If the dispute is over the vehicle's value or repair cost, an independent auto appraiser or policy appraisal process is generally more relevant than hiring a homeowners-style public adjuster.
Can You Trust Your Insurance Adjuster?
You can work professionally with an adjuster without assuming the adjuster represents your financial interests.
Those are different concepts.
I would trust:
- Written policy language
- Photographs
- Independent estimates
- Receipts
- Written insurer decisions
more than a casual verbal statement such as:
“Don't worry, we'll take care of everything.”
Professional, Not Personal
You don't need to treat the adjuster like an enemy. You also shouldn't treat the conversation like advice from someone whose job is to maximize your recovery.
What Are the Worst Insurance Companies to Deal With?
I would not name one company as America's universal “worst insurer.”
A giant insurer handling millions of claims will naturally generate more complaints than a small regional carrier.
Instead, compare companies using:
- State insurance department complaint information
- NAIC complaint information
- Complaint ratios relative to company size
- Financial condition
- Claims-service data
- Your state's regulatory actions
Raw Complaint Numbers Can Mislead
Ten thousand complaints against an enormous insurer are not directly comparable with 300 complaints against a tiny company. Complaint ratios and the type of complaint provide more context.
Look particularly for recurring complaints involving:
- Claim delays
- Low settlement offers
- Coverage denials
- Communication problems
- Cancellation or nonrenewal
How Do You Get an Adjuster to Call You Back?
This is one of the most frustrating parts of a difficult claim.
Do not simply leave ten angry voicemails.
Get Direct Contact Information
Ask for the adjuster's direct phone number and email address.
Use the Claim Number Every Time
Make it easy to identify your file.
Send a Short Written Follow-Up
State what you need and the date of your previous request.
Keep a Communication Log
Document dates, calls, emails and promises.
Call the Main Claims Department
If the adjuster repeatedly does not respond, ask for a supervisor.
Ask for Another Adjuster
If communication has completely broken down, ask whether the company can reassign the claim.
Escalate in Writing
A concise documented escalation is generally stronger than repeated emotional calls.
A Useful Follow-Up
“Claim #12345: I emailed on October 28 and October 31 regarding the supplemental repair estimate and have not received a response. Please confirm receipt and advise the next step and expected review date.”
When to Escalate the Claim
Consider escalating when:
- The adjuster repeatedly ignores communications
- The estimate omits documented damage
- The insurer cannot explain a deduction
- The claim is denied without a clear explanation
- The company repeatedly asks for documents already supplied
- Deadlines appear to be ignored
Escalation can include:
- Claims supervisor
- Internal appeal
- Appraisal
- State insurance department complaint
- Public adjuster for an appropriate property claim
- Attorney when necessary
When to File an Insurance Department Complaint
Every state has an insurance regulator.
A complaint may be appropriate for issues involving:
- Unreasonable claim delays
- Failure to communicate
- Possible violations of claims-handling laws
- Unexplained denial
- Failure to honor policy provisions
The regulator generally cannot simply decide that your roof is worth $27,000 instead of $20,000.
But it can require the insurer to explain its handling and determine whether state insurance laws were followed.
Documentation Becomes Powerful Here
A complaint containing dates, emails, estimates, policy provisions and written insurer responses is much easier to evaluate than “my insurance company is terrible.”
When an Attorney May Make Sense
Not every insurance dispute needs a lawyer.
A $1,200 bumper dispute probably does not justify the same response as a catastrophic injury claim.
Legal advice may become more important when:
- Injuries are serious
- Permanent disability is possible
- Liability is heavily disputed
- A large claim has been denied
- The insurer alleges fraud or misrepresentation
- You are asked to give sworn testimony
- Damages substantially exceed insurance limits
- A lawsuit has been filed
See Should You Get a Lawyer After a Car Accident?
Better Things to Say Instead
| Instead of Saying | Consider Saying |
|---|---|
| “I guess I was doing 50.” | “I don't know my exact speed.” |
| “The leak was probably there for months.” | “I first discovered the water on this date.” |
| “It was completely my fault.” | “Here is what happened from my perspective.” |
| “I'm fine.” | “I don't know yet whether I was injured.” |
| “Whatever you offer is fine.” | “Please send me the estimate and explain how the amount was calculated.” |
| “That must be all the damage.” | “Is there a supplemental process if additional damage is discovered?” |
| “I don't remember, but probably...” | “I don't remember.” |
These Are Not Magic Phrases
Use them only when they are truthful. The goal is accuracy, not scripting a false version of events.
Bottom Line
The insurance adjuster may be polite, experienced and completely professional.
But the insurance-company adjuster still works for the insurance company.
That relationship matters.
The Best Claim Strategy Is Surprisingly Simple
Tell the truth.
Don't guess.
Don't exaggerate.
Don't minimize.
Don't sign something you don't understand.
Document everything.
From the claim experiences people repeatedly describe, one pattern stands out: the casual comment you forget five minutes later may remain in the claim file long after the conversation ends.
So if you do not know how fast you were going, say you don't know.
If you discovered the leak yesterday but don't know when it started, give the discovery date.
If you do not know whether you're injured yet, don't make a medical conclusion ten minutes after the crash.
If the first estimate seems incomplete, ask how it was calculated and how to submit additional documentation.
And if the first settlement offer arrives before you understand the full loss, do not confuse fast with fair.
You do not need to outsmart the adjuster. You need to make your claim harder to misunderstand, undervalue or deny.
Related Insurance Claim Guides
- Insurance Adjuster Lowballed You? Don't Accept Until You Check These Numbers
- Pros and Cons of Hiring a Public Adjuster for Home Insurance Claims
- Insurance Company Delaying Your Claim? Bad Faith Warning Signs
- Insurance Denial Letter? 9 Things to Check Before You Give Up
- Hidden Insurance Exclusions: Fine Print That Can Wreck a Claim
- Insurance Claim Closed? Keep Records for Years
- Cash Offer After a Car Accident: Pros, Cons & Smart Decision Guide
- Diminished Value Claim After a Car Accident
- What to Do After a Car Accident
Helpful Resources
- NAIC: How to File an Insurance Complaint
- NAIC Consumer Insurance Search and Complaint Information
- Texas Department of Insurance: Working With an Insurance Adjuster
- Florida Department of Financial Services: Public Adjusters
- California Department of Insurance: What to Do After an Accident
Frequently Asked Questions FAQ’s
How do insurance adjusters trap you?
Not every adjuster is trying to trap a claimant, but questions can hurt a claim when you guess, speculate or make broad statements that later conflict with evidence. Give accurate facts, distinguish what you know from what you assume, and do not manufacture answers simply because you feel pressured to respond immediately.
What won't an insurance adjuster tell you?
An adjuster may not proactively identify every possible way you could increase your recovery. Ask about supplemental estimates, replacement-cost benefits, recoverable depreciation, appraisal rights, rental coverage, loss of use and other policy benefits that may apply to your claim.
How do you outsmart an insurance adjuster?
Trying to trick an adjuster is the wrong strategy. The better approach is to out-document the claim with photographs, videos, estimates, receipts, timelines, policy language and written communication. Accurate evidence is much harder to dispute than clever wording.
What's the biggest mistake people make with an insurance claim?
One of the biggest mistakes is guessing about facts they do not know. Statements about speed, fault, how long damage existed or the cause of a loss can become important later. If you genuinely do not know, say so.
Can you trust your insurance adjuster?
You can work professionally with an adjuster, but remember that a company or independent adjuster handling the insurer's claim represents the insurance company rather than you. Verify important information through written policy language, estimates and written claim decisions.
Do insurance adjusters try to lowball claims?
Claimants sometimes receive estimates substantially below their contractor, repair shop or valuation evidence. That does not prove intentional lowballing in every case. If the offer seems too low, ask how it was calculated and submit documentation supporting a higher amount.
Should I take the first settlement offer from the insurance company?
Do not accept or reject an offer merely because it is the first one. Compare it with the actual damages, repair estimates, medical needs and policy benefits. Be especially cautious about signing a release before you understand whether additional damages or treatment may arise.
What should I not tell my insurance company?
Do not lie or hide material information. Also avoid guessing. If you do not know how long a hidden leak existed, your exact speed or the full extent of damage, say what you actually know and provide additional information when it becomes available.
Do I have to give an insurance adjuster a recorded statement?
It depends on who is asking and your policy obligations. You generally have no insurance contract with the other driver's insurer, so its request is different from a request made by your own insurer. Your own policy may require cooperation and may permit recorded statements or other examinations. Review your policy and obtain advice when a significant claim creates uncertainty.
Can I hire a public adjuster for an auto insurance claim?
Public adjusters are most commonly used for first-party property claims such as homeowners losses. Routine auto disputes generally use different options, including body-shop supplements, independent auto appraisers, policy appraisal procedures, insurance regulators or attorneys depending on the dispute.
What are the worst insurance companies to deal with?
There is no reliable universal worst-company ranking. Large insurers naturally generate more raw complaints because they insure more people. Compare state complaint ratios, NAIC complaint information, regulatory history, financial condition and claims-service data instead of relying only on online reviews.
How do you get an insurance adjuster to call you back?
Use the claim number in every communication, email a concise written request, keep a contact log and escalate to a claims supervisor if repeated calls or emails are ignored. If communication delays become unreasonable, your state insurance department may be able to review a formal complaint.
